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Hong Kong-South Africa

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CbC Exchange MoU between Hong Kong and South Africa Signed

According to an update from the South African Revenue Service, a Memorandum of Understanding on the exchange of Country-by-Country (CbC) Reports has been signed with Hong Kong. The MoU provides that CbC reports voluntarily filed by Hong Kong MNE groups in Hong Kong for the 2016 and 2017 fiscal years will be exchanged with South Africa, and given that exchange, South Africa will not require local filing of CbC reports in South Africa by such MNE groups.

Note - As per the Hong Kong Inland Revenue's CbC reporting guidance page (and OECD guidance), the voluntary filing of CbC reports in Hong Kong will only serve to relieve local filing obligations in other jurisdictions with respect to the 2016 reporting fiscal year if the required legal framework is put in place in Hong Kong by 31 December 2017 (generally the first CbC report deadline in other jurisdictions). The passage of the relevant legislative amendment to the Inland Revenue Ordinance is pending.

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